Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Penalty u/s 271(1)(c) - Non-consideration of reply filed by the assessee - the order levying penalty suffers from violation of principle of natural justice and non-application of mind by the AO and the same cannot be allowed to stand. The AO has not exercised his power to levy penalty in a fair, reasonable and judicial manner - Penalty order quashed - AT
Penalty u/s 271(1)(c) - Non-consideration of reply filed by the assessee - the order levying penalty suffers from violation of principle of natural justice and non-application of mind by the AO and the same cannot be allowed to stand. The AO has not exercised his power to levy penalty in a fair, reasonable and judicial manner - Penalty order quashed - AT
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